The European Commission has issued a new notice to stakeholders regarding how the UK’s withdrawal from the EU will affect the field of biocidal products.

Although the UK withdrew from the EU in February, EU law, including the Biocidal Products Regulation (BPR, Regulation (EU) No 528/2012), still applies to the UK until the transition period ends on 31 December 2020.

Some of the key issues for biocides stakeholders are:

  • UK-based suppliers on the Article 95 list should appoint a representative established in the EU and submit a request for correction to ECHA;
  • UK-based authorisation holders should transfer the authorisation to a new holder established in the EU;
  • Data protection and data sharing mechanisms provided for in the BPR continue to apply to UK-based companies;
  • Low-risk biocidal products authorised in the UK via the simplified procedure and notified to EU Member States cannot be put on the EU market after the end of the transition period;
  • Shipments of treated articles from the UK to the EU will be considered as imports after the end of the transition period, and the person placing the treated article on the market must ensure that it complies with the BPR;
  • UK-based companies will still have access to the R4BP register for certain processes;
  • After the end of the transition period, EU Member States cannot issue parallel trade permits where the country of origin is the UK;
  • Certain provisions of EU law will remain applicable in Northern Ireland. Biocidal products placed on the market in Northern Ireland must still comply with the BPR, and establishment requirements are fulfilled by being established in Northern Ireland.

The stakeholder notice, which supersedes some previous documents, can be downloaded from ECHA’s website.

If you have any queries or would like to discuss how we can assist you to meet your obligations, please send an email to or contact the team on +353 1 849 5284.